School-official designation
Per 34 CFR 99.31(a)(1)(i)(B), Koydo qualifies as a school official with a 'legitimate educational interest' when (a) Koydo performs an institutional service or function for which the school would otherwise use employees, (b) Koydo is under the direct control of the school with respect to the use + maintenance of education records, (c) Koydo is subject to the requirements of 34 CFR 99.33(a) governing redisclosure.
Direct control test (the four pillars)
(1) Data is used only for the educational purpose documented in the DPA. (2) Data is not shared with non-school parties without authorization. (3) Data is subject to the same restrictions Koydo applies to other school employees handling educational records. (4) Data may be re-used only with authorization OR for the originally-authorized educational purpose.
What constitutes an educational record on Koydo
Roster data, attendance, gradebook entries, lesson notes, homework submissions, IEP documents (when contracted with the school). Lesson recordings are educational records when retained beyond the 90-day default. Aggregate de-identified metrics are NOT educational records.
Parental access rights
Parents of minor students retain the right to inspect + review their child's educational records under FERPA §1232g(a)(1)(A). The Koydo parent portal (/parent + /parent/data-export) gives parents direct access without requiring a formal FERPA records request to the school.
Directory information policy
Koydo does NOT disclose directory information (student name, photo, etc.) to third parties without explicit parental consent. The school's directory information policy is honored if more restrictive than Koydo's defaults.
Annual notification
The school remains responsible for the annual FERPA notification to parents under §99.7. Koydo provides a template paragraph describing Koydo's role as a school official that schools can include in their annual notification.
Records of disclosure
Koydo maintains a record of all disclosures of educational records under §99.32. In practice, this record is empty for normal Koydo operation (Koydo processes; doesn't disclose). Records available to parents on request.